Overview
A. Description of the Advisory Firm
Dedeker Financial, LLC (hereinafter “DFL”) is a Limited Liability Company organized in
the State of Minnesota. The firm was formed in August 2022, and the principal owners are
Kenneth Dedeker and Todd Kelzenberg.
B. Types of Advisory Services
Portfolio Management Services
DFL offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. DFL creates an Investment
Policy Statement for each client, which outlines the client’s current situation (income, tax
levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a
portfolio that matches each client's specific situation. Portfolio management services
include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
DFL evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. DFL will request discretionary authority from clients in order to
select securities and execute transactions without permission from the client prior to each
transaction. Risk tolerance levels are documented in the Investment Policy Statement,
which is given to each client.
DFL seeks to provide that investment decisions are made in accordance with the fiduciary
duties owed to its accounts and without consideration of DFL’s economic, investment or
other financial interests. To meet its fiduciary obligations, DFL attempts to avoid, among
other things, investment or trading practices that systematically advantage or
disadvantage certain client portfolios, and accordingly, DFL’s policy is to seek fair and
equitable allocation of investment opportunities/transactions among its clients to avoid
favoring one client over another over time. It is DFL’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent among its
clients on a fair and equitable basis over time.
DFL may direct clients to third-party investment advisers to manage all or a portion of
the client's assets. Before selecting other advisers for clients, DFL will always ensure those
other advisers are properly licensed or registered as an investment adviser. DFL then
makes investments with a third-party investment adviser by referring the client to the
third-party adviser. DFL will not review the ongoing performance of the third-party
adviser as a portion of the client's portfolio.
Financial Planning
Financial plans and financial planning may include,
but are not limited to: investment
planning; life insurance; tax concerns; retirement planning; college planning; and
debt/credit planning.
Services Limited to Specific Types of Investments
DFL generally limits its investment advice to mutual funds, fixed income securities,
insurance products including annuities, equities, ETFs (including ETFs in the gold and
precious metal sectors), treasury inflation protected/inflation linked bonds and non-U.S.
securities. DFL may use other securities as well to help diversify a portfolio when
applicable.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. The way we make money
creates some conflicts with your interests, so we operate under a special rule that
requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in
your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
C. Client Tailored Services and Client Imposed Restrictions
DFL will tailor a program for each individual client. This will include an interview session
to get to know the client’s specific needs and requirements as well as a plan that will be
executed by DFL on behalf of the client. DFL may use model allocations together with a
specific set of recommendations for each client based on their personal restrictions, needs,
and targets. Clients may not impose restrictions in investing in certain securities or types
of securities in accordance with their values or beliefs.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees and transaction costs. DFL does not participate in wrap fee
programs.
E. Assets Under Management
DFL has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 102,000,000.00 $ 5,000,000.00 December 2023